Joint Comments of CDT and EFF on Proposed Policies and Findings Pertaining to the Smart Grid

[Ed. Note: These comments were submitted to the California Public Utilities Commission. The Samuelson Law, Technology & Public Policy Clinic at UC Berkeley School of Law drafted the comments for CDT.]

The Smart Grid promises great benefits to consumers and the environment, including lowered energy costs, increased usage of environmentally friendly power sources, and enhanced security against attack and outage. At the same time, however, the Smart Grid presents new privacy threats through its enhanced collection and transmission of detailed consumption data – data that can reveal intimate details about activities within the home and that can easily be transmitted from one party to another.

The challenge for the Commission is to develop rules that both protect the consumer against misuse of this data and empower the consumer to access this data, use it and share it with entities other than the utility as they offer new and useful services to consumers.